Case 9:08-cv-80736-KAM Document 358 Entered on FLSD Docket 01/29/2016 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:08-80736-Civ-Marra JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE NO. 1 AND JANE DOE NO. 2'S REPLY IN SUPPORT OF MOTION TO COMPEL ANSWERS TO SUPPLEMENTAL REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION COME NOW Jane Doe No. 1 and Jane Doe No. 2 (the "victims"), by and through undersigned counsel, to file this reply in support of their motion to compel the Government either to provide answers to certain requests for admission and requests for production involving Epstein lawyer Alan Dershowitz or, in the alternative, to properly assert privilege over these discovery requests. The discovery requested is clearly relevant to this case. In their motion to compel, the victims explained at length four specific reasons why the requested information is important to the victims' claims. In response, the Government ignores several of the reasons and offers no convincing response to the others. In particular, the Government fails to contest the fact that Dershowitz's participation in plea discussions regarding Epstein's sex offenses while also a witness to or co-conspirator in the activity would be, in and of itself, a violation of the victims' right to fairness. 18 U.S.C. § 3771(aX8). And the Government also fails to acknowledge that (in stark contrast to normal criminal cases) Dershowitz and other members of the Epstein defense team were deeply involved in crafting the timing and content of victim notifications in this case. EFTA02756064